When an AML Backlog Becomes a Compliance Problem

A backlog is rarely just a resourcing issue.

Unreviewed transaction monitoring alerts may contain activity that should have been investigated further. Historical investigations may not have adequately considered whether reasonable grounds to suspect were reached. Suspicious transactions may have gone unreported, reports may have been delayed, or documentation may not adequately demonstrate how decisions were reached.

These issues can emerge through:

• transaction monitoring backlogs;

• internal compliance testing;

• AML effectiveness reviews;

• regulatory examinations;

• staff turnover or resource shortages;

• weaknesses in historical investigation procedures;

• ineffective monitoring scenarios;

• poor escalation practices; or

• concerns about the quality or timeliness of previous STR filings.

Platino Consulting helps organizations determine the extent of the issue and build a defensible remediation process.

End-to-End AML Remediation

Platino Consulting can manage the remediation as a defined compliance project rather than simply supplying additional analysts.

Scope the Historical Population

We help establish what needs to be reviewed, the relevant period, affected customers and transactions, applicable monitoring scenarios and potential regulatory reporting exposure.

Establish the Remediation Methodology

Investigation procedures, escalation criteria, documentation standards, reasonable-grounds-to-suspect decision frameworks and quality-assurance requirements are established before production begins.

Build and Manage the Remediation Team

Where additional capacity is required, Platino Consulting can support the selection, onboarding and management of experienced AML investigators while maintaining centralized governance over the project.

Investigate Historical Activity

Alerts, transactions, customer information, historical activity and relevant contextual information are reviewed to determine whether further escalation is required.

Review Potential STR Obligations

Where suspicious activity is identified, the circumstances are assessed against applicable reporting requirements and documented appropriately.

Support STR Preparation and Reporting

Where the reporting threshold is met, Platino Consulting can support the preparation and quality review of Suspicious Transaction Reports and the remediation of historical regulatory reporting deficiencies.

Implement Quality Assurance

QA provides consistency across investigators, validates decisions and helps ensure remediation work can withstand subsequent internal, independent or regulatory review.

Correct the Underlying Control Failure

Clearing a backlog does not resolve the problem if the process that created it remains unchanged.

Platino Consulting identifies root causes and can help improve transaction monitoring, escalation procedures, investigation standards, staffing models, governance, policies and reporting processes.

Transaction Monitoring Backlog Remediation

Platino Consulting has experience leading large-scale transaction monitoring remediation projects, including cryptocurrency and financial-institution environments.

Our work can include:

• project planning and governance;

• investigator recruitment and onboarding;

• alert investigation;

• enhanced due diligence;

• name screening;

• STR assessment;

• quality assurance;

• productivity and quality KPIs;

• management reporting;

• escalation frameworks;

• scenario and threshold analysis; and

• transition from remediation into sustainable business-as-usual monitoring.

The objective is not simply to close alerts. It is to complete the historical review appropriately while strengthening the control environment that remains after the remediation project ends.

Experience Managing Complex AML Backlogs

In one cryptocurrency engagement, Platino Consulting was engaged to lead the remediation of a two-year transaction monitoring backlog.

The engagement included project scoping, governance, specialist resourcing, investigations, quality assurance and subsequent optimization of the transaction monitoring environment.

The project ultimately moved beyond backlog clearance into improvements intended to reduce unnecessary alerts and create a more sustainable ongoing monitoring process.

STR Remediation Following an Effectiveness Review

An independent AML effectiveness review can identify weaknesses in transaction monitoring, investigations or regulatory reporting.

Finding the deficiency is only the first step.

Platino Consulting can remain involved after an effectiveness review to help management:

• determine the historical exposure;

• develop the remediation plan;

• conduct lookback reviews;

• investigate potentially suspicious activity;

• address regulatory reporting deficiencies;

• document corrective action; and

• demonstrate that identified findings have been remediated.

Learn About AML Effectiveness Reviews

Who We Support

STR and transaction monitoring remediation may be relevant to:

Money Services Businesses
Fintech and Payment Companies
Virtual Currency and Cryptocurrency Businesses
Financial Institutions
Securities Dealers
Mortgage Businesses
Real Estate Businesses
Financing and Leasing Companies
Dealers in Precious Metals and Stones
Other FINTRAC Reporting Entities

The remediation methodology is adapted to the organization's business model, regulatory obligations, customer population and underlying financial-crime risks.

Resolve the Backlog. Fix the Control Environment.

Historical AML deficiencies become more difficult to manage the longer they remain unresolved.

Platino Consulting provides experienced AML remediation leadership to help organizations understand the problem, investigate the affected activity, address regulatory reporting obligations and implement sustainable corrective action.

Discuss Your AML Remediation Project